Comment Number: 522418-09168
Received: 7/14/2006 12:43:21 AM
Organization: LNM Enterprises
Commenter: Louis Scotti
State: NY
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am an Independent Business Owner with Quixtar. I am writing in regards to the proposed Business Opportunity Rule. While I agree with your objective to see to it that consumers have access to enough truthful information to be able to make an informed decision, I feel that some of the proposed rules would create an unfair burden to the development of my business. I have been an IBO for six years. The business fundamentals and people skills that I have learned in this business have benefitted me and my family in both my proffessional career as a Podiatrist as well as a husband and father. This business will soon provide the income to allow my wife to come home from work and be a full time mom. Requiring that a prospect be given a list of local IBO's is potentially unfair. There would be nothing to prevent a person in whom I have already invested my time and effort from being "stolen" and registered by one of these IBO's. I would compare this to my Podiatry practice. If someone came in to be seen with a specific problem, would I want to have to give him a list of ten other Podiatrists who also treat that problem? The same argument can be made with the Litigation rule. It would be unreasonable to expect a Podiatrist to have to give all law suits against all Podiatrists to any patient that was considering treatment. Certainly the requirement of "informed consent' in medical procedures carries a very high burden. Yet, we are not required to give this information, in part, because it is not neccessarily germain to the patient, and would only cause confusion and anguish. Thank you for reading my comments. Sincerely, Dr. Louis Scotti